We may add to, or amend, this Policy with other notices. We may also
post different privacy policies for some Services and, when we do so,
this Policy does not apply. For example, where applicable, separate
policies apply to information collected from your device through Tell
HTC Usage and Tell HTC Error Reporting.
NOTE: Your wireless operator, mobile operating system provider and/or third-party
applications, toolbars, services, “plug-ins”, social media platforms and
websites may also collect, use and share information about you and your
device and your usage. HTC’s privacy policies do not cover any third
parties, their products, actions or their services. HTC does not control
how third parties collect, use or secure your data. For information
about third-party privacy practices, please consult their privacy
policies. Only download applications from, and interact and connect
with, reputable third parties.
INFORMATION YOU GIVE US
When you use our Services, you may
provide information to us, both online and offline, including, for
example: your name, email address, street address, phone numbers, fax
number, date of birth, device identifiers, location data, your provider
information, photos, videos and demographics (gender, company or
organisation name, occupation, language preference, city, country,
postcode, area code, time zone, etc.). If you purchase Services from us,
we may also store your credit card numbers or other payment information,
as required. We may hold and associate any information you provide us
with together with information gathered from other sources, including
the social accounts that you choose to associate with your use of the
Services, or with information we receive from other companies.
INFORMATION WE AUTOMATICALLY COLLECT
When you use the Services, we
automatically collect some information. We may collect information about
your usage of and activity on our Services. When you visit our websites,
information we may automatically log includes, for example, your
operating system, Internet Protocol (IP) address, access times, browser
type and language and the website that you visited before visiting our
website. When you use our devices, download and use our applications, or
access the Services from your device, we may also log information
related to your device and your use of our applications and Services. We
may log, for example, the date you activate your device, your location,
phone number, device type, serial number, device identifiers (e.g.,
IMEI, MEID, serial number, CID, MID and MCC ID Number or SIM card ID),
the types and versions of mobile operating systems on your device,
applications and software you install and use and how you use them,
content you view or use and time-stamped logs of data exchanges.
use the Services to back up and store your device data and content with
an independent third party service provider, we will collect certain
information needed to help restore your data and content to your device,
such as your device settings and the names of files and applications
that you wish to back up. We may also log information about you using
web beacons, cookies, local shared objects (LSOs) and similar methods as
described in our
. We may automatically link any of the
information that we collect about you using these methods, to
information that you provide us and any other information that we
collect about you in accordance with this Policy.
For the United States:
For the EU:
Usage Data and Error Reporting
In addition to the information we automatically collect, as described
above, we may collect more detailed de-identified data about your device
usage and error report data about your device (formerly called Tell HTC
Experience and Tell HTC Error Report on older devices). When you
participate in these programmes, you help us to understand how you use
your device and improve HTC devices and other HTC and trusted partner
products and services. HTC may re-identify this data when appropriate;
for example, when you request technical support, choose to use a
specific HTC service or app, or create an HTC Account. To learn more
about usage and error reporting on your device, and/or to change your
option to participate, go to “Settings” on your device. Usage and error
data settings will not affect HTC’s collection of de-identified
activation data or data about specific HTC apps and services you choose
to use, including HTC Account, and are otherwise subject to limitations
described in this Policy.
Others, including third party analytics
service providers and third party ad service providers, as described in
the section below, may also automatically collect the same or similar
information about you and your device when you use the Services,
including personally identifiable information about your online
activities over time and across third party website and applications.
INFORMATION COLLECTED THROUGH THIRD PARTY
Some of our HTC e-store
is operated by third parties, such as Luzern. When you purchase
products through that e-store you enter into terms and conditions with
site. Luzern is a data controller in its own right. Luzern
share certain user transaction data with us for our sales reports,
better understanding of customer behavioural analysis or other
legitimate purpose as described in this Policy.
Other information for Advertising
We may use third-party ad
service providers to serve ads in our Services. We may also use third
parties to deliver or help us deliver HTC-branded ads to you on
third-party websites. To deliver these ads, third parties automatically
collect certain information about you and your devices and your use of
the Services. This information may include visits to the websites and
applications of HTC and others, your IP address, your Internet service
provider, and the browser that you use to visit our website. Third
parties may collect information by using cookies as described in our
HTC may use information collected through third-party
cookies or beacon in our Service or email for purpose to serve better
ads to you on third-party websites. We may know when you visit HTC
website after you browse such third-party websites and use the
information collected about you to serve tailored ads to your interests
through our Services or third-party service.
USE OF YOUR PERSONAL INFORMATION
HTC may use your information, including personal information, as follows:
To provide requested services or perform a contract with you
provide and deliver products and Services that you request;
process the post transaction requested by you, such as refund;
send you information related to your requests, queries and purchases,
including confirmations, invoices, technical notices, updates, security
alerts and support and administrative messages;
Where we have your consent
Where we have a legitimate interest in improving your customer experience and the quality of
the Services provided to you:
To send you marketing communications including about contests,
promotions, rewards, upcoming events and news about products and
services offered by HTC and our selected partners (we do this as per
your choices) and to process and deliver contest entries and rewards.
operate and improve our websites, products, Services and marketing;
To respond to your comments and questions and provide customer
To compile information to be able to provide you with a
personalised and customised experience, content, marketing and
recommendations across all our Services (in line with your choices as
relates to receiving any direct marketing communications);
or combine your personal information with other information we get about
your use of other HTC Services and from third parties for the purposes
that we disclose in this policy, including to help understand you and
your needs, and provide you with recommendations, better service and
To filter the content to be displayed as part
of the Services;
To compile usage and other statistics and insights
relating to the Services;
To prevent, investigate and deter against
fraudulent, unauthorised or illegal activity, and ensure network and
information security; and
To facilitate sharing of information and
content that you choose to upload via social media (for example if you
choose to upload content on the HTC forum or other applications, this
may be made available for others to see through such forum).
Where we have a legal obligation
To protect, investigate and deter against
fraudulent, unauthorised or illegal activity.
Where your personal information is necessary for us to be able to
provide you with requested services we make this clear on collection. If
you decline to provide us with this information or object to continued
processing of this information we will be unable to provide such
requested services to you.
If you object to the processing of your
personal data for marketing communication or if you withdraw your
consent, we are obliged, according to data protection law, to enter the
required data (name, e-mail address) into our internal emailing system
in order to ensure the ongoing observance of your objection or of your
withdrawal of consent. We will use your blocked data exclusively for
MORE ABOUT LOCATION DATA
When you use certain Services, we may
collect, process, store and share your precise location data. This
location information may include real-time geographic location of your
device. It may also include the names of places that you have been,
where you choose to “check-in”, to determine, log or share your
location, places that you mark on a map, the geographic location, dates
and other metadata of photos that you’ve taken, routes that you have
travelled, how close you are to other devices, such as Bluetooth-enabled
devices, Wi-Fi routers and services that use those devices (such as a
store’s tracking of your movement for data collection and marketing
purposes) and the dates and times that you were at certain locations.
HTC may share your location data with application providers who show
that they have the right permissions. HTC may associate location data
with personally identifiable or identifying information, such as your
device ID and your account information. Our Services may also collect
precise location data in a de-identified form, and we may share this
data with partners and carriers to improve features and services.
SHARING OF PERSONAL INFORMATION
INFORMATION YOU SHARE
may allow you to connect and share your actions, comments, content and
information publicly or with people you specify. You may also connect
to, and share your information on, third-party social media platforms,
websites, applications and services (“Third Party Sharing Services”)
through “plug-ins,” widgets, buttons, and other third party features
made available on and connected with our Services. Please be mindful of
your own privacy needs as you choose who to connect with and what to
share and make public. We cannot control the privacy or security of
information that you choose to make public or share with others. We also
cannot control and are not responsible for any Third-Party Sharing
Services or their actions, including the data that these Third-Party
Sharing Services collect from you and your device, or how they use such
data. Please review the privacy policies of all Third-Party Sharing
Services to understand their privacy practices.
INFORMATION WE SHARE
We may share your personal information as follows where it is lawful to do so:
With your consent
. We share your personal information with ad
network providers where you have given your consent. We also share your
personal information with co-branded partners where you have consented
to this. Our partners’ use of your personal information will be subject
to their privacy policies.
For the purposes of a business deal (or
negotiation of a business deal) involving a sale or transfer of all or a
part of our business or assets
. Business deals may include any merger,
financing, acquisition or bankruptcy transaction or proceeding.
For legal, protection, security and safety purposes:
With service providers
who process personal information as part of services
to us and who are subject to appropriate contractual obligations.
to comply with
laws or regulatory requirements and to respond to lawful requests and
to protect the rights and property of HTC, our
agents, customers and others, including enforcing our agreements,
in an emergency, including protecting the safety of
our employees and agents, our customers or any other person.
With wireless carriers for their provision of services to you
. Their use of
your information is subject to their privacy policies.
We may share aggregated and de-identified data with others for any purpose.
WHERE WE STORE YOUR INFORMATION AND TRANSFER OF YOUR INFORMATION
Information that we collect may be stored on your phone or stored on our
servers and transferred to, stored and processed in the United States,
Taiwan, Singapore, People’s Republic of China, United Kingdom, other EU
member state countries (such as Poland) and any other country where HTC
or its service providers maintain facilities, depending on where you use
our product and services. Where your personal information is transferred
from within the EU to outside the European Economic Area (EEA), security
measures and appropriate safeguards are put in place to protect your
information and we ensure that all transfers of your information comply
with applicable data protection law, and are carried out in accordance
with our instructions. We have in place the relevant EU Model Clauses*
with any party (including HTC Corporation) your information is
transferred to outside the EEA, as an adequate safeguard. To find out
more about how we safeguard your information (including obtaining a copy
of such safeguards) in relation to transfers outside the EEA, please
contact us via the details provided in the contact section below.
* EU Model clauses means standard clauses for transfer of personal
information to a controller established in third party countries under
European Commission decision 2001/497/EC of 15 June 2001, as amended by
European Commission decision 2004/915/EC of 27 December 2004, and the
standard clauses for transfer of personal information to processors
established in third countries under European Commission decision
2010/87/EC of 5 February 2010.
Information that we collect may be retained for as long
as needed to fulfil the purposes outlined in the “use of your personal
information” section above, or for a period of time specifically
required by applicable regulations or laws such as retaining the
information for tax and accounting purposes. When determining the
relevant retention periods, we will take into account factors including:
Otherwise, we securely
erase your information once this is no longer needed. Contact us if you
would like more information on how long we retain your information.
our contractual obligations and rights in relation to the
legal obligation(s) under applicable law to
retain data for a certain period of time;
statute of limitations under applicable law(s);
(potential) disputes; and
issued by relevant data protection authorities.
By law, you have a number of rights (subject to
certain conditions) when it comes to your information. Further
information and advice about your rights can be obtained from the data
protection regulator in your country. You can exercise any of these
rights by contacting us through our contact information below.
right to object to processing.
You have the right to object to certain
types of processing, including processing for direct marketing (i.e.
receiving emails from us notifying you about other services which we
think will be of interest to you or being contacted with varying
The right to be informed
. You have the
right to be provided with clear, transparent and easily understandable
information about how we use your information and your rights. This is
why we’re providing you with the information in this Policy.
right of access
. You have the right to obtain access to your information
(if we’re processing it), and certain other information (similar to that
that we’re using your information in accordance with data protection
The right to rectification
. You are entitled to have your
information corrected if it is inaccurate or incomplete. You can request
that we rectify any errors in information that we hold.
The right to erasure.
This is also known as ‘the right to be forgotten’ and, in
simple terms, enables you to request the deletion or removal of your
information that we hold.
The right to restrict processing
have rights to ‘block’ or supress further use of your information. When
processing is restricted, we can still store your information, but will
not use it further. We keep lists of people who have asked for further
use of their information to be ‘blocked’ to make sure the restriction is
respected in the future.
The right to data portability
. You have
rights to obtain and reuse your information for your own purposes across
different services. For example, if you decide to switch to a new
provider, this enables you to move, copy or transfer your information
easily between our IT systems and theirs safely and securely, without
affecting its usability. This is not a general right however and there
The right to lodge a complaint
. You have the right
to lodge a complaint about the way we handle or process your information
with your national data protection regulator.
The right to withdraw
. If you have given your consent to anything we do with your
information (i.e. we rely on consent as a legal basis for processing
your information), you have the right to withdraw your consent at any
time (although if you do so, it does not mean that anything we have done
with your personal data with your consent up to that point is unlawful).
You can withdraw your consent to the processing of your information at
Where your personal information is collected within the
European Economic Area (EEA), you can contact us through the contact
information of HTC Europe Co. Ltd to exercise any of those rights
INFORMATION CHOICES AND CHANGES
Our marketing emails tell you how
to “opt out” of receiving further marketing emails. If you opt out, we
may still send you non-marketing emails. Non-marketing emails include
emails about your accounts and our business dealings with you, and may
include a request that you participate in surveys related to your use
of, and satisfaction with, the Services.
You may send requests about
your personal information to us through our contact information below.
You can request to change contact choices or marketing choices and to
update, access, delete or make other changes regarding your personal
information or content that you post on the Services in line with your
rights above. We may not honour all such requests unless required by
When you use our Services, we and third parties may give you
choices about use of certain mechanisms for tracking, including tracking
of your online activities over time and across different websites,
applications and online services. We may provide settings on your device
that allow you to change how we, and others, collect certain information
about you. Read your product manual for more information about settings
on your device. Many browsers are set to accept cookies unless and until
you change your settings.
Removing or rejecting our cookies could affect
how our websites and Services work for you and could delete or disable
opt-out cookies set by us and third parties.
Some of our third party ad
tailored to your profile and preferences.
To learn more visit:
While we and others give you certain choices, as further outlined in this Policy, there are
many ways in which Web browser signals and similar mechanisms can
indicate your choice to disable tracking, and we may not be aware of nor
honour every such mechanism.
PROTECTION OF YOUR PERSONAL INFORMATION
We strive to protect
personal information by taking appropriate physical, technical and
organisational measures to help guard against unauthorised or unlawful
access, use, processing or alteration of the personal information that
we obtain from you through our Services and against any breaches or loss
of such personal information, such as anonymization, pseudonymization,
encryption (such as encrypted by Transport Layer Security (HTTPS) during
transmission), restricted access, etc.. Although we take steps to use
and improve various safeguards, no system or technology is completely
secure. If you become aware of a technical vulnerability affecting HTC
Services, please email
or visit this website to report
it. If you have a concern related to the protection of personal
information or this Policy, please send an email to
HTC Account lets you use a single user name and
password to log on to
and other HTC applications and
Services. Some HTC applications and Services require a different user
name and password. Please protect your user names and passwords to help
prevent anyone from accessing your accounts and your personal
We are not responsible for the security of any independent
third-party applications and services or the data those third-party
applications and services may collect about you. Please ask those third
parties how they keep your data safe.
We welcome your comments or questions about
this Policy. Please email us at
. You may also
contact us in writing at the addresses listed below:
HTC America, Inc.
308 Occidental Ave. South, Suite 300 Settle, WA 98005
Attention: Privacy Administrator
23 Xinghua Road,
Company registration number: 16003518
HTC Europe Co. Ltd
Salamanca, Wellington Street
Slough, Berkshire SL1 1YP, U.K.
Company registration number: 04826012
Attention: Privacy Administrator
(HTC Europe Co. Ltd is the leads
establishment of HTC Corporation for the EU.)
CHANGES TO THIS
We may make changes to this Policy. If we make any
changes to the Policy they will be posted on this page and we will
change the “Last Updated” date below.
UPDATED ON 25th MAY 2018.
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